PAD definitions

note the definition of "Propellant actuated device":

=== BATFE

27 CFR 555 - Commerce in Explosives [Revised as of April 1, 2003] Subpart B--Definitions, Sec. 555.11 Meaning of terms.

Propellant actuated device. Any tool or special mechanized device or gas generator system which is actuated by a propellant or which releases and directs work through a propellant charge.

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now note the definition of related, but distinct "Propellant-actuated power devices" ("Propellant-actuated power devices" that use other than smokeless powder are considered "explovesive-actuated power devices" in this CFR)

=== U.S. Department of Labor

29 CFR 1910 Explosives and Blasting Agents [Revised as of July 1, 2003]

1910.109(a)(8)

"Propellant-actuated power devices." Propellant-actuated power devices - any tool or special mechanized device or gas generator system which is actuated by a smokeless propellant or which releases and directs work through a smokeless propellant charge.

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the following state codes only define the 29 CFR term "propellant-actuated power device", but the 27 CFR definition

=== Washington State Revised Code of Washington, Title 70 - Public Health and Safety RCW 70.74.010 - Definitions.

(23) The term "propellant-actuated power device" shall be held to mean and include any tool or special mechanized device or gas generator system which is actuated by a propellant or which releases and directs work through a propellant charge.

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] === California Code of Regulations Title 8 Subchapter 7. General Industry Safety Orders, Group 18. Explosives and Pyrotechnics, Article 113. Explosives and Pyrotechnics

5237. Definitions.

"Propellant-Actuated Power Devices." Any tool or special mechanical device or gas generator system which is actuated by a propellant, or which releases and directs work through propellant charge.

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while this states use the 27 CFR term "Propellant-actuated device", but the 29 CFR definition (see "smokeless powder" reference)

=== Minnesota Rules Dept. of Public Safety - Explosives, Blasting Agents, Firearms

7500.0100 Definitions, Subp. 11. Propellant-actuated device.

"Propellant-actuated device" means a tool or special mechanized device or gas generator system that is actuated by a smokeless propellant or that releases and directs work through a smokeless propellant charge.

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this is the only one who seems to have it right, using the 29 CFR term and definition

=== Delaware Code Title 16, Health and Safety, Part VI - Safety Chapter 71. Sale, Purchase, Receipt, Possession, Transporation, Use, Safety and Control of Explosive Materials

7102. Definitions

(6) "Propellant-actuated power devices or tools" shall mean any tool or special mechanized device or gas generator system which is actuated by smokeless propellant or which releases and directs work through a smokeless propellant charge. It does not include explosive-actuated devices. (7) "Explosive-actuated devices" shall mean any tool or special mechanized device which is actuated by explosives, other than smokeless propellants.

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Nebraska Administrative Code Title 272-Nebraska State Patrol, Chapter 5 Scope and Definitions

003 Definitions.

003.16 "Propellant-Actuated Power Devices" shall mean any tool or special mechanized device or gas generator system which is actuated by a smokeless propellant or which releases and directs work through a smokeless propellant charge.

http://216.239.39.104/search?q=cache:uhlQSWO0xwoJ:

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finally, here are some industry references with examples of PADs

=== Black and Smokeless Powders: Technologies for Finding Bombs and the Bomb Makers (1998) Commission on Physical Sciences, Mathematics, and Applications Appendix I: Glossary

Propellant-actuated device (PAD)

See Cartridge-actuated device.

Cartridge-actuated device (CAD)

A self-contained device employing smokeless powder or black powder as the primary source of working gas to drive a piston to do mechanical work. Examples include air-bag-inflation devices, bomb-ejection cartridges, cable cutters, fire-extinguishing systems, parachute-release mechanisms, flight-recorder-ejection systems, and aircraft-seat-ejection units.

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Cartridge and Propellant Actuated Device National Security Assessment of the Cartridge and Propellant Actuated Device Industry

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EXECUTIVE SUMMARY - Background (excerpted)

The aerospace sector is the major user of CAD/PAD items. Many are used in life saving applications under emergency conditions. Major uses include aircrew ejection seats found on high speed aircraft, chaff and flare ejectors used as countermeasures to anti-aircraft missiles, bomb rack and missile releases, and missile fuel igniters. Commercial use has increased rapidly, especially with the advent of automotive airbag initiators, which are being phased in as a mandatory Federal safety requirement. Other commercial uses have also increased. These include mining and oil field development devices, emergency cutting tools, and fire extinguisher actuators. ===

- iz

Reply to
Ismaeel Abdur-Rasheed
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iz: so whats your point? State PAD definitions are almost taken verbatim from Federal PAD definitions....thats nothing new... do the same research and you will find a number of states that has copied the BATFE Explosives List verbatim in to their state law, including APCP being a explosive.... So if you live in certain states and you play with APCP you better be sure and have a state explosives permit, not only the BATFE one.... Because remember, the BATFE tells you to be in local and state compliance too....and last time I heard, you would much prefer to goto Federal prison than "good old boys State prison" if you catch my drift..... And I know this will make me unpopular, but I still say the PAD definition as far a rocket engine is concerned is a stretch....sorta like a "hail-mary" toss.... Nobody even knew what a PAD was , or that it supposedly defined a rocket engine, until all this BATFE LEUP BS started.... I never heard anybody refer to a rocket engine as a PAD..... "Wow, IZ, thats a mighty big PAD you got there in that rocket... what size PAD does that model take. Boy I wish the prices on these PAD prices would come down....yeah right....wishful thinking....take a look at the historical record .....not one mention of a rocket engine as a PAD.... There is a whole aerospace industry around PADS/CADS and the last time I looked, none were rocket motors...... This whole PAD thing kinda reminds me of the 62.5g limit that the NAR/TRA is fighting the BATFE over...we say they are trying to impose the 62.5 g limit, when the 62.5 g limit has already been imposed upon us by our own organizations via NFPA codes..... since 1968 too....

shockie B)

"Ismaeel Abdur-Rasheed" wrote in message news:lsVzb.345156$ snipped-for-privacy@twister.nyc.rr.com...

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Reply to
shockwaveriderz

==

CA

Group 18. Explosives and Pyrotechnics Article 113. Explosives and Pyrotechnics

?5237. Definitions.

"Explosives." Any substance or combination of substances that is commonly used for the purpose of detonation or rapid combustion which upon exposure to any external force or condition is capable of relatively instantaneous release of gas and heat.

"Explosives-Actuated Power Devices." Any tool or special mechanical device which is actuated by explosives, but not to include propellant actuated power devices. Examples of explosive actuated devices are jet perforators, shaped charges and similar devices.

==

DOT

...... Articles, pyrotechnic for 1.4S UN0432 II

1.4S..... None.......... 62........ None...... 25 kg 100 kg A technical purposes.

...... Cartridges, actuating, ........... ................... .......... ............. ......... ......... ........... ........... ............ for aircraft ejector seat catapult, fire extinguisher, canopy removal or apparatus, see Cartridges, power device.

...... Cartridges, power device. 1.3C UN0275 II

1.3C..... None.......... 62........ None...... Forbidden 75 kg B

...... Cartridges, power device. 1.4C UN0276 II

1.4C..... 110 None.......... 62........ None...... Forbidden 75 kg A 24E

...... Cartridges, power device. 1.4S UN0323 II

1.4S..... 110, 63............ 62........ None...... 25 kg 100 kg A

==

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Other Issues

Several non-economic issues also adversely impact the CAD/PAD industry. These predominantly involve government regulations concerning the environment, worker safety, and the transport of hazardous materials, export barriers, and small business set-asides. Another issue is government competition with private industry.

Classification of shipping: Nearly half the respondents described a lengthy and burdensome approval process to transport explosives for non-government contracts. CAD/PAD manufacturers must obtain a recommendation for classification from the American Association of Railroads, Bureau of Explosives (a private industry association), or from the Interior Department's Bureau of Mines. The recommendation is forwarded to the Department of Transportation, Office of Hazardous Materials, which issues a "letter of competent authority" to the manufacturer, who may then ship the product.

CAD/PAD firms reported the Bureau of Explosives lacks the resources to provide this service in a timely fashion. In extreme cases it has taken about a year. The Bureau of Mines typically provides the service in 1-3 months, but the fee is often excessive, ranging up to $450 to over $6,000, and the schedule unpredictable and insensitive to firm's planning. The Office of Hazardous Materials is currently issuing letters of competent authority to shippers in about one week. The Agency is also attempting to lessen the burden on industry by permitting items to be classified by grouping, worst case, or blanket classifications for like items.

==

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[my experience is measured in tens of thousands of dollars, and also several YEARS waiting]
Reply to
Jerry Irvine

....yeah

I'm starting to lean the other way, Shocky. The aircraft ejection seats have been in use for a long time. While I haven't actually seen or heard one used, I've watched Wings enough to know that I could put my Mini Magg up perty high on one. An aircraft ejection seat rocket motor is a PAD. Why isn't a Mini Magg motor a PAD too?

steve

Reply to
system user

rocket motors qualify as "Propellant-actuated devices" (PAD) as defined in 27 CFR

29 CFR has a definition for a similar but distinct "Propellant-actuated power devices" (PAPD)

rocket motors do not qualify as the 29 CFR defined PAPD, as they are not made from smokeless propellant

some states have confused the definitions, juxtaposing the definition of one with the term for the other, and as some states use the 29 CFR PAPD definition for the 27 CFR PAD term, the federal 29 CFR PAPD and those states PAD terms are synonomous

  • Note that this is not an example of "State PAD definitions are almost taken verbatim from Federal PAD definitions", but a complete redefinition of the 27 CFR term

ergo, rocket motors do not qualify as a PAD (for the purpose of State regulations), in those states WHERE the 27 CFR PAD definition has been replaced the 29 CFR PAPD definition

I have seen a mining application, where what is indistinguishable from a rocket motor is used to launch a projectile at the cave ceiling to cause unstable formations to fall, resulting in a safer environment. (I am still trying to locate that web reference, but I recall they use APCP specifically). That device is a PAD.

Earlier in the history of HPR, an ATF agent was asked if there were any federal explosives regulations that applied to rocket motors. The agent denied any applicability as they are exempt as PADS.

I am trying to find the eye-witness account.

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Reply to
Ismaeel Abdur-Rasheed

It doesn't make any difference if a rocket motor can be considered a PAD. APCP is *clearly* not an explosive by the definition in the law as passed by Congress. If it can be regulated in violation of the law, PAD exemptions are even less likely to keep our APCP from regulation.

Tom

Reply to
Tom Binford

verily, yee speak Truth in its fullness

- iz ;)

Tom B> It doesn't make any difference if a rocket motor can be considered a PAD.

Reply to
Ismaeel Abdur-Rasheed

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Reply to
Jerry Irvine

they do use a rocket motor..

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seems the Gemini spacecraft used rocket assisted ejection seats
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Anybody know who made these rocket motors ?

shockie B)

have been in use

Reply to
shockwaveriderz

The 62.5g limit in the NFPA codes is to separate model rockets (for children) from high power rockets. That has nothing to do with the ATF or their asinine attempts to require explosives permits for non-explosive materials.

Reply to
RayDunakin

Then you agree that there is historical evidence of rocket motors being referred to as PADS?

steve

Reply to
system user

Yet as the moron you truly are regarding laws you do not see, or perhaps cannot see, that NAR imposes a per motor limit of 62.5g on ADULTS despite the:

  1. FAA waiverless limit of 113g
  2. The FAA notification limit of 125g
  3. The NAR MR limit of 125g
  4. The NFPA MR limit of 125g
  5. The TRA MR limit of 125g
  6. The Irvine 1983-5 unified 125g proposal on which 2, 3, 4, 5 arose.

Just the oracle of truth Jerry

Reply to
Jerry Irvine

"CAD/PADs are specialized work performing components used in many modern weapon systems. The cartridges use precisely measured propellant and explosive mixtures of varying compositions and burning characteristics that perform a wide variety of jobs within the weapon systems. They range in cost from about $1 to over $10,000 and may be purchased one at a time or by the thousands. The aerospace sector is the major user of CAD/PAD items. Many are used in life saving applications under emergency conditions. Major uses include aircrew ejection seats found on high speed aircraft, chaff and flare ejectors used as countermeasures to anti-aircraft missiles, bomb rack and missile releases, and missile fuel igniters. Commercial use has increased rapidly, especially with the advent of automotive airbag initiators, which are being phased in as a mandatory Federal safety requirement. Other commercial uses have also increased. These include mining and oil field development devices, emergency cutting tools, and fire extinguisher actuators."

I see no mention of PADS/CADS being model rocket or high power rocket engines used for sport flying.......

shockie B)

Reply to
shockwaveriderz

whats the difference between a propellant actuated device and an explosive propellant actuated device? shockie B)

Reply to
shockwaveriderz

a PAD uses a non-explosive propellant; i.e. the phenomena of pressurization arising from expanding cases is not the result of an explosion

a EAD functions explicitly by explosion

- iz

shockwaveriderz wrote:

Reply to
Ismaeel Abdur-Rasheed

the use of the terms "MANY are used in ...", "MAJOR uses INCLUDE ..." and "These INCLUDE ..." show that the list is not intended to be all-inclusive. Other uses are possible and still satisfy the definition

- iz

shockwaveriderz wrote:

Reply to
Ismaeel Abdur-Rasheed

it doesnt matter, ATF is going to enforce the law in whatever way they feel like it anyways....

Reply to
tai fu

So you expect them to list every possible use instead of examples as they have done?

Bob

Reply to
baDBob

Hobby is a minor and currently declining use. Negative growth does that to an industry.

Jerry

Reply to
Jerry Irvine

The NAR/TRA lawsuit is, of course, addressing the PAD issue. But you are correct, BATFE's official position is that rocket motors do not meet the definition(s) of PAD/EPAD and are not exempt from BATFE explosive regulation.

Reply to
Gary

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